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Over The Counter Derivatives (OTC) Reporting Requirements

Mayer Brown Free Writings + Perspectives

No-Action Letter on “Group” Reporting under Section 13(d) and 13(g) for Parties to OTC Derivatives Contracts

On January 23, 2026, the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission issued a letter in which it stated it would not object if a large investment bank (the “Bank”) determines...more

A&O Shearman

ESMA launches selection of CTP for OTC derivatives

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The European Securities and Markets Authority (ESMA) has announced the launch of its first selection procedure for a consolidated tape provider (CTP) for over-the-counter (OTC) derivatives. ESMA encourages interested entities...more

A&O Shearman

ESMA Final Draft RTS Under MiFIR Review On Derivatives Transparency, Package Orders And Input And Output Data For The Derivatives...

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The European Securities and Markets Authority (ESMA) has published its final report under the MiFIR Review on derivatives transparency, package orders, and the over-the-counter (OTC) derivatives consolidated tape input and...more

Katten Muchin Rosenman LLP

UK EMIR Update: Intragroup Exemption Consultations and Additional Q&As

On 5 November 2025, HM Treasury (HMT) published a draft statutory instrument, the Over-the Counter-Derivatives (Intragroup Transactions) Regulations 2026 (draft SI), together with a policy note, and the UK Financial Conduct...more

A&O Shearman

ESRB And IOSCO Publish Final Reports Analysing Credit Default Swaps Market

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The European Systemic Risk Board (ESRB) has published a report analysing the credit default swaps (CDS) market, with a particular focus on single-name CDSs in terms of their market structure and current regulatory framework....more

A&O Shearman

Delegated regulation on identifying reference data for OTC derivatives published in OJ

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Commission Delegated Regulation (EU) 2025/1003 has been published in the Official Journal of the European Union (OJ), supplementing the EU Markets in Financial Instruments Regulation (MiFIR) as regards over-the-counter...more

Ropes & Gray LLP

Capital Markets & Governance Insights - January 2025

Ropes & Gray LLP on

Companies should not minimize the extent of a material cybersecurity incident by omitting material facts regarding the scope and potential impact of the incident. Cybersecurity risk factor disclosures should be tailored to a...more

Blake, Cassels & Graydon LLP

Publication par les ACVM des modifications finales aux règles de déclaration des opérations sur dérivés de gré à gré

Le 25 juillet 2024, les Autorités canadiennes en valeurs mobilières (les « ACVM ») ont publié les modifications finales (les « modifications ») aux règles de déclaration des opérations sur dérivés de gré à gré applicables...more

Blake, Cassels & Graydon LLP

Final Amendments to Canada’s OTC Derivatives Trade Reporting Rules Released

On July 25, 2024, the Canadian Securities Administrators (CSA) published final amendments (Amendments) to the over-the-counter (OTC) derivatives trade reporting rules applicable in each province and territory (including OSC...more

Proskauer Rose LLP

SEC Adopts New Securities Lending Reporting Rule

Proskauer Rose LLP on

On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted new Rule 10c-1a (the “Securities Lending Rule”), requiring the reporting of certain securities lending transactions. Certain material terms of...more

Blake, Cassels & Graydon LLP

Les ACVM publient un règlement sur la conduite commerciale en dérivés

Contexte ​- Après un processus de consultation qui aura duré 10 ans, les Autorités canadiennes en valeurs mobilières (les « ACVM ») ont publié le Règlement 93-101 sur la conduite commerciale en dérivés (le « Règlement »),...more

Blake, Cassels & Graydon LLP

Derivatives Business Conduct Rule Issued by the Canadian Securities Administrators

Background - After a 10-year long consultation process, the Canadian Securities Administrators (CSA) have published Multilateral Instrument 93-101 – Derivatives: Business Conduct (Rule), a core regulation governing dealing...more

Blake, Cassels & Graydon LLP

Canadian Securities Administrators Propose Amendments to OTC Derivatives Trade Reporting Rules

The Canadian Securities Administrators (CSA) have published proposed amendments (Proposed Amendments) to the Provincial Trade Reporting Rules (defined below). The Proposed Amendments are meant to streamline Canada’s...more

Stikeman Elliott LLP

CSA Seek Comments on Enhanced OTC Derivatives Data Reporting Amendments

Stikeman Elliott LLP on

Proposed amendments are intended to reduce regulatory burden by aligning over-the-counter (OTC) derivatives data reporting requirements with international standards developed by the Committee on Payments and Market...more

White & Case LLP

THE DELTA REPORT - Derivatives Newsletter - October 2020: Contemporary Saudi Arabian OTC derivatives legislation

White & Case LLP on

The Saudi Arabian Monetary Authority ("SAMA") issued the SAMA Rules on Trade Repository Reporting & Risk Mitigation Requirements for Over-the-Counter ("OTC") Derivatives Contracts (the "Rules") in November 2019, replacing the...more

Akin Gump Strauss Hauer & Feld LLP

Changes to EMIR Reporting Responsibilities from 18 June 2020 – Key Considerations

Derivatives reporting responsibilities under the European Market Infrastructure Regulation (EMIR) will change from 18 June 20201, as (i) alternative investment fund managers (AIFMs) will become responsible for reporting for...more

Latham & Watkins LLP

Reporting of OTC Derivatives Between FC and NFC- Entities After 18 June 2020

Latham & Watkins LLP on

EMIR REFIT Mandatory Reporting provisions require market participants to consider their existing Delegated Reporting arrangements. Key Points: ..From 18 June 2020, financial counterparties (FCs) will be liable for the...more

A&O Shearman

International Bodies Issue Report on Governance Arrangements for Derivatives Data

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The Committee on Payments and Market Infrastructures and the International Organization of Securities Commissions have published a joint report on governance arrangements for critical data elements for over-the-counter...more

A&O Shearman

Financial Stability Board Publishes Governance Arrangements for Unique Product Identifier

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The Financial Stability Board has published a report on governance arrangements for the Unique Product Identifier, a globally harmonized code identifying over-the-counter derivatives products reported to trade repositories....more

Perkins Coie

SEC and FINRA Staffs Issue Joint Statement on Broker-Dealer Custody of Digital Asset Securities

Perkins Coie on

The staffs of the Division of Trading and Markets (Division) of the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) (collectively, the “Regulators”) published a joint...more

A&O Shearman

EU Capital Requirements Directive V and Capital Requirements Regulation II Finalized

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The legislative amendments to the EU's Capital Requirements Regulation and the Capital Requirements Directive, widely referred to as "CRD5" or "CRR2", have been published in the Official Journal of the European Union. Subject...more

Akin Gump Strauss Hauer & Feld LLP

Brexit: Recognition of UK Derivatives Regulation

• Under Swiss law, to fulfil the clearing, reporting and risk mitigation obligations applying to derivatives trading under foreign law, the Swiss Financial Market Supervisory Authority (FINMA) must recognize the foreign law...more

A&O Shearman

Statement by EU Supervisory Authority Confirms No EU Transitional Measures For UK Credit Rating Agencies and Trade Repositories on...

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The European Securities and Markets Authority has issued a public statement urging customers of credit rating agencies and trade repositories to prepare for a "no deal" Brexit. The European Market Infrastructure Regulation...more

Herbert Smith Freehills Kramer

Projet de règlement de la Commission européenne modifiant le règlement 648/2012 dit « règlement EMIR »

This alert examines the draft Commission Regulation amending Regulation 648/2012 aka « EMIR Regulation » and Communication from the Commission to the EU Parliament and Council as well as to the European Central Bank. ...more

Cadwalader, Wickersham & Taft LLP

European Commission Adopts Proposal to Amend EMIR

On 4 May 2017, the European Commission (the “Commission”) adopted a proposal for a Regulation amending Regulation (EU) No 648/2012 (“EMIR”) as regards the clearing obligation, the suspension of the clearing obligation, the...more

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